The plaintiff alleged that it had performed some work related to a Hartford sports stadium before the city formally cut ties with the plaintiff. The plaintiff then filed suit related to the hiring of a stadium manager. It acknowledged that the city’s counsel never signed a lawful contract with the plaintiff, but stated that nonetheless the city effectively ratified an otherwise invalid agreement when it asked for and paid two of the plaintiff’s invoices before other city officials cut off the payments and repudiated them.

The plaintiff relied on the 2015 case Bellsite Development, LLC v. Monroe, 155 Conn. App. 131, which held that a municipality may validate an otherwise invalid contract when it later accepts benefits, in order to defeat the holding in Fennell v. Hartford, 283 Conn. 809 (1996) – a municipality can only be bound to a promise by the formal method defined by its law.

The court, in granting summary judgment to the city, held that any action that would be deemed ratified under Bellsite must be ratified by the entity with the power to contractually bind the municipality and nothing in Bellsite suggests that it was meant to overrule Fennell. The court also rejects the plaintiff’s argument that the city’s actions were subject to CUPTA liability because this case did not involve trade or commerce.

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